20060417Application for intervenor funding.pdf

LOUIS F. RACINE "917-2005)
WILLIAM D. OLSON
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL'
JOHN B. INGELSTROM
DANIEL C. GREEN"
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
MITCHELL W. BROWN
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.
DAVID E- ALEXANDERtt
LANE V. ERICKSON"
LISA M. CHRISTONttt
PATRICK N. GEORGE
SCOTT J. SMITH
LISA A. WOOD, CPA
STEPHEN J. MUHONEN
BRENT L. WHITING
LISA R. TANNER;
JUSTIN R. ELLIS
JOSHUA D. JOHNSONttt
JONATHON S. BYINGTON
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE' [phone]
FACSIMILE, [phone]
201 EAST CENTER STREET
POST OFFICE. BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]FACSIMILE [phone] IDAHO FALLS OFFICE
www.racinelaw.net
477 SHOUP AVENUESUITE 203A
IDAHO FALLS, ID 83402
TELEPHONE. [phone]FACSIMILE. [phone]
SENDER'S E-MAIL ADDRESS: elotgiracinelaw.net 'ALSO MEMBER WY '" IL BARS
"ALSO MEMBER UT BAR
tALSO MEMBER D. C. BAR
ttALSO MEMBER MO BAR
tttALSO MEMBER IL BAR
*ALSO MEMBER CA BAR
April 13 , 2006
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Dear Mrs. Jewell:
Re:IPC-O5-
...,",
Enclosed herewith for filing, please find the following:
RCB:rr
Enclosurescc: Service List
Original and seven copies of Application for Intervenor Funding of the Idaho
Irrigation Pumpers Association.
Original and eight copies of Comments of the Idaho Irrigation Pumpers Association.
,' )
Randall C. Budge, ISB No. 1949
Eric L. Olsen, ISB No. 481l
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
, -
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Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE TO ELECTRIC
CUSTOMERS IN THE ST ATE OF IDAHO.
CASE NO. IPC-O5-
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION. INe.
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), by and through
counsel of record, Randall C. Budge, and hereby respectfully makes application to the Idaho Public
Utilities Commission ("Commission ) for intervenor funding pursuant to Idaho Code ~ 61-617 A and
Rules 161-165 of the Commission s Rules of Procedure as follows:
(1 )A summary of the expenses that the Irrigators request to recover broken down into
legal fees, consultant fees and other costs and expenses is set forth in Exhibit "A" attached hereto
and incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to
Exhibit "B" in support of said summary and are incorporated by reference.
(2)The detail of the Irrigators' proposed findings and recommendations are set forth in
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 1
the Direct Testimony and Exhibits of Anthony J. Yankel filed March 1 , 2006. This Testimony was
prepared by the Irrigators ' witness Yankel with the assistance of counsel to comply with the
Intervenor Testimony deadline of March 3 2006 , and had been substantially completed prior to the
settlement discussions conducted between the Parties on February 7 2006 and February l4, 2006
which resulted in the Settlement Stipulation dated February 27, 2006 ("Stipulation ). The only
changes to the Irrigators' Testimony prepared after the Stipulation were modifications to pages 2
lines 11-, and page 3, lines 11-, to set forth the Irrigators ' support ofthe Stipulation.
Had the case not settled, the Irrigators would have addressed power supply costs
disproportionate growth and allocation of growth between classes, and irrigation load curtailment
program issues as detailed in the Direct Testimony of witness Yankel. Mr. Yankel's testimony was
filed for the purpose of setting forth in detail the competing issues the Irrigators intended to raise in
this proceeding had the case not settled and to provide a supporting basis for this Application.
Paragraph 10 of the Stipulation does provide a mechanism for addressing issues relating to
the Peak Rewards Program. However, it will be necessary for the Irrigators to address and resolve
issues relating to disproportionate growth and the allocation of the cost of growth between classes
in future proceedings. Notwithstanding, for purposes of this case, the Irrigators support the
Stipulation as a reasonable compromise under the circumstances.
(3)The expenses and costs incurred by the Irrigators set forth in Exhibit A and
accompanying attachments are reasonable in amount and were necessarily incurred. The Irrigators
legal counsel and consultant fully participated in the case, actively reviewed the filings, prepared
and filed Data Requests and reviewed the Company Responses to multiple Requests ofthe parties
prepared Direct Testimony and Exhibits, and participated in settlement discussions that resulted in
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 2
the Stipulation presented to the Commission for approval. It was necessary for the Irrigators to
prepare this case as though it were going to full hearing as has been the case with all Idaho Power
general rate cases for many years.
(4)The costs incurred by the Irrigators as above described constitut a financial hardship
for the Irrigators. The Irrigators currently have approximately $11 599 in the bank and accounts
payable as a result of participation in this case as set out in Exhibit "A" and other accounts payable
relating to the Irrigators' participation in this and prior rate cases in the approximate amount of
$50 133. No amounts have been paid to date towards the costs incurred by the Irrigators in this case.
The Irrigators are an Idaho nonprofit corporation qualified under LR.C. ~ 501(c)(5)
representing farm interests in electric utility rate matters affecting farmers in southern and central
Idaho. The Irrigators rely solely upon dues and contributions voluntarily paid by members, together
with intervenor funding to support activities and participate in rate cases. Each year a mailing is sent
to approximately 7500 Idaho Irrigators (approximately two-thirds in the Idaho Power Company
service area and one-third in the Utah Power Company service area), soliciting annual dues. The
Irrigators recommend that each member make a voluntary contribution based on acres irrigated or
ofthirty cents ($.30) per horsepower for each pumping installation. Member contributions have
been diminishing each ofthe last several years, primarily due to the depressed agricultural economy
that has ben exacerbated by costs imposed by newly-formed ground water districts to provide
mitigation to surface water right holders and to deal with other issues in dispute concerning water
rights in the East Snake Plain Aquifer. From member contributions the Irrigators must pay all
expenses, which generally include mailing expenses, meeting expenses and shared office space in
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 3
Boise, Idaho, in addition to the expenses relating to participation in rate cases. The Executive
Director, Lynn Tominaga, is the only part-time paid employee, receiving a small retainer plus
expenses for office space, office equipment, and secretarial services. Officers and directors are
elected annually and serve without compensation.
It has been and continues to be a financial hardship for the Irrigators to fully participate in
all rate matters affecting its members. As a result of financial constraints, participation in past rate
cases and in this case has been selective and, primarily, on a limited basis.
(5)The Irrigators' Proposed Findings and Conclusions are set forth in the Direct
Testimony of Anthony J. Yankel. Because the Staff Testimony was not filed, it cannot be
determined with certainty how the Irrigators' Proposed Findings and Recommendations differed
materially from the Testimony and Exhibits of the Commission Staff. However, based on
discussions with the Commission Staff prior to the settlement concerning the issues the Staff
intended to address, the Irrigators believed that positions and recommendations being asserted as
identified in the Irrigators ' Direct Testimony would in fact have materially differed from that ofthe
Commission Staff.
(6)The Irrigators ' participation addressed issues of concern to the general body of users
or consumers on Idaho Power system. Frequent rate increases are being driven by substantial capital
expenditures which have been and will be incurred by Idaho Power to meet significant load growth.
The Company s methods for allocating these costs is an issue substantially focused upon by the
Irrigators and it is important to all customers to establish cost allocation methodologies that fairly
and equitably assign the cost of system growth. Furthermore, since summer peak load has
disproportionately grown, maintaining and expanding the Irrigation Peak Rewards Program as a
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 4
viable DSM program producing tangible benefits to the Company as well as ratepayers is certainly
an issue of concern to the general body of ratepayers.
(7)The Irrigators represent the irrigation class of customers under Schedule 24.
Based on the foregoing, it is respectfully submitted that the Irrigators are a qualifying
intervenor pursuant to Idaho Code ~61-617A and Rules 161-165 of the Commission Rules of
Procedure and should be entitled to an award of reasonable costs incurred as Intervenor funding in
the amounts requested.
~h...
DATED this day of April 2006.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
~L&4
RANDALL C. BUDGE
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 5
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this J"3 day of April, 2006, I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
e-mail: jjewell(illpuc.state.id.
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
bkline(illidahopower. com
mmoen~idahopower .com
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
rgale(illidahopower .com
Donald L. Howell, II
Cecelia A. Gassner
Deputy Attorneys General
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-00074
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Peter J. Richardson
Richardson & O'Leary
O. Box 7218
Boise, Idaho 83702
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
Conley E. Ward
Givens Pursley LLP
O. Box 2720
Boise, Idaho 83701-2720
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty St. S., Ste 250
Salem, Oregon 97302
Lawrence A. Gollomp
Assistant General Counsel
S. Department of Energy
1000 Independence Ave., S.
Washington, DC 20585
Dennis Goins
Potomac Management Group
O. Box 30225
Alexandria, VA 22310-8225
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC, - 6
Ken Miller
NW Energy Coalition
5400 W. Franklin, Suite G
Boise, Idaho 83705
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
36 E. Seventh St., Ste 1510
Cincinnati, OH 45202
Neal Townsend
Energy Strategies
215 S. State Street, Suite 200
Salt Lake City, UT 84111
~j~
RANDALL C. BUD
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 7
EXHIBIT "
SUMMARY OF EXPENSES INCURRED BY IRRIGATORS
CASE NO. IPC-05-
LEGAL - RANDALL C. BUDGE:
Legal Fees: 37.80 Hours (ill $175/185 $ 6 867.
Total:$ 6 867.
CONSULTING FEES - TONY Y ANKEL:
Consulting Fees: 207 hours (ill $125 $25 875.
Total:25.875.
TOT AL FEES AND EXPENSES:$32 742.
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 8
EXHIBIT
BILLIN G STATEMENTS
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 9
Date: 04/11/2006 Detail Fee Transaction File List Page: 1
RACINE, OLSON, NYE, BUDGE AND BAILEY CHARTERED
Trans Hours
Client Date Atty P Tcd Rate to Bill Amount Ref#
Client ID 710.1518529 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
710,1518529 11/09/2005 RCB A 175,210,00 RECEIVE AND REVIEW IDAHO POWER POWER GENERAL ARCH
RATE CASE FILING; PREPARE FILE PETITION TO
INTERVENE; TELEPHONE CONFERENCE WITH AND
LETTER TO L. TOMINAGA, T. YANKEL RE: CASE REVIEW
INTERVENTION AND ISSUES TO ADDRESS BY IIPA
710,1518529 11/23/2005 RCB A 175,210,00 TELEPHONE CONFERENCE WITH T, YANKEL RE: IIPA ARCH
FIRST DATA REQUEST; PREPARE FILE AND SERVE IIPA
FIRST DATA REQUESTS TO IPCO; TELEPHONE
CONFERENCE WITH D, HOWELL RE: CASE STATUS,
PROPOSED SCHEDULE, IMPACT OF S02 CASE VIA PCA
CREDIT, ETC.
710.1518529 12/09/2005 RCB A 175,210,00 TELEPHONE CONFERENCE WITH T, YANKEL RE: IPCO ARCH
FILING ISSUES, STRATEGY; PREPARE FILE SECOND
DATA REQUESTS
710,1518529 12/16/2005 RCB A 175,52,50 TELEPHONE CONFERENCE WITH T, YANKEL RE:ARCH
DISCOVERY RESPONSES AND ISSUES AND POSITION
DEVELOPMENT FOR BOARD MEETING AND REVIEW
710,1518529 12/19/2005 RCB A 175,140,00 PREPARE FILE AND IIPA THIRDS DATA REQUEST TO IPCO ARCH
710,1518529 01/05/2006 RCB A 175,210,00 RECEIVE AND REVIEW PROPOSED SCHEDULE, IPCO ARCH
OBJECTIONS TO DISCOVERY REQUESTS; ATTEND
SCHEDULING CONFERENCE; TELEPHONE CONFERENCE
WITH T, YANKEL RE: SAME
710,1518529 01/06/2006 RCB A 175,105,00 RECEIVE AND REVIEW IPCO OBJECTIONS TO THIRD ARCH
DATA REQUESTS 45-50 TO IPCO; TELEPHONE
CONFERENCE WITH T, YANKEL RE: SAME
710,1518529 01/10/2006 RCB A 175,105,00 REVIEW AND RESPOND TO PROPOSED SCHEDULING ARCH
ORDER; EVALUATE AND PREPARE RESPONSE TO IPCO
OBJECTIONS TO DATA REQUESTS
710,1518529 01/14/2006 RCB A 175,87,50 TELEPHONE CONFERENCE WITH T, YANKEL RE:ARCH
ANALYSIS AND CHALLENGE OF COST OF SERVICE
ISSUES
710,1518529 01/17/2006 RCB A 175,210,00 MEETING WITH STAFF RE: RATE CASE ISSUES AND ARCH
POSITION DEVELOPMENT; MULTIPLE TELEPHONE
CONFERENCES WITH T, YANKEL AND B, KLINE RE: IPCO
OBJECTIONS TO 3RD DATE REQUEST; IRRIGATORS COS
ISSUES
710,1518529 01/18/2006 RCB A 175,262,50 MEETING WITH IPCO (B, KLINE, M. BRILLS, C, NESBITT)ARCH
AND CONFERENCE CALL WITH T, YANKEL RE: REVIEW
OF "IRRIGATION PEAK REWARDS" PROGRAM AND 2005
ANNUAL REPORT; RESOLVE IPCO OBJECTIONS TO IIPA
3RD DATA REQUESTS
710,1518529 01/31/2006 RCB A 175,105,00 RECEIVE AND REVIEW IPCO RESPONSES TO IIPA 3RD ARCH
DATA REQUESTS; TELEPHONE CONFERENCE WITH T,
YANKEL RE: PROPOSED DRAFT TESTIMONY AND
ADDRESSING IRRIGATION CURTAILMENT AND PEAK
CLIPPING COS AND PRICING ISSUES
710,1518529 02104/2006 RCB A 185,370.00 REVIEW IPCO TESTIMONY AND EXHIBITS, T, YANKEL ARCH
DAFT TESTIMONY AND EXHIBITS, STAFF SETTLEMENT
CONFERENCE ISSUES; TELEPHONE CONFERENCE WITH
T. YANKEL RE: SAME
710,1518529 02/06/2006 RCB A 185.407,00 REVIEW- REVISE AND EDIT WITH T, YANKEL PROPOSED ARCH
TESTIMONY AND EXHIBITS AND ISSUES FOR IPCO
SETTLEMENT CONFERENCE; TELEPHONE CONFERENCE
WITH T. YANKEL RE: PROPOSED TESTIMONY AND
REVISIONS; LETTER TO PARTIES WITH IRRIGATOR
ISSUES FOR SETTLEMENT CONFERENCE
710,1518529 02/07/2006 RCB A 185,610,50 PARTICIPATE IN IPCO SETTLEMENT CONFERENCE (VIA ARCH
PHONE); MULTIPLE TELEPHONE CONFERENCE WITH T,
YANKEL, D, HOWELL, L. TOMINAGA RE: SAME
710,1518529 02/08/2006 RCB A 185,OAO 74,00 TELEPHONE CONFERENCE WITH D. HOWELL, TO,ARCH
YANKEL RE: IPCO SETTLEMENT ISSUES AND
NEGOTIATIONS
710,1518529 02/14/2006 RCB A 185,462,50 MULTIPLE TELEPHONE CONFERENCES WITH L.ARCH
TOMINAGA, T, YANKEL RE: STATUS AND STRATEGY FOR
IPCO SETTLEMENT CONFERENCE; PARTICIPATE IN IPCO
SETTLEMENT CONFERENCE (VIA TELEPHONE)
710,1518529 02/15/2006 RCB A 185,185,00 MULTIPLE TELEPHONE CONFERENCES WITH STAFF (R.ARCH
LOBB, D, HOWELL), IPCO (B, KLINE), L. TOMINAGA, T,
YANKEL RE: PROPOSED SETTLEMENT AGREEMENT
SEPARATE PROCEEDING PROPOSAL RELATING TO
IRRIGATION CURTAILMENT PROGRAM CHANGES
710,1518529 02/16/2006 RCB A 185,92,50 REVIEW PROPOSED SETTLEMENT AGREEMENT AND ARCH
STAFF REVISIONS; TELEPHONE CONFERENCE WITH L.
TOMINAGA, T. YANKEL RE: SAME
710,1518529 02117/2006 RCB A 185,92.50 TELEPHONE CONFERENCE WITH L. TOMINAGA, VARIOUS ARCH
BOARD MEMBERS RE: PROPOSED SETTLEMENT
710,1518529 02/18/2006 RCB A 185,148,00 BOARD CONFERENCE CALL MEETING RE: PROPOSED ARCH
IPCO SETTLEMENT STIPULATION
ASS Tuesday 04/11/200611:23
Date: 04/11/2006 Detail Fee Transaction File List Page: 2
RACINE, OLSON, NYE, BUDGE AND BAILEY CHARTERED
Trans Hours
Client Date Atty P Tcd Rate to Bill Amount Ref #
Client ID 710.1518529 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
710,1518529 02/21/2006 RCB A 185,92,50 TELEPHONE CONFERENCE WITH T, YANKEL AND ARCH
MEETING WITH ELO RE: IPCO SETTLEMENT STIPULATION
AND PREPARE SUPPORTING COMMENTS AND
INTERVENOR FUNDING APPLICATION AND SUPPORTING
INFORMATION
710,1518529 02/22/2006 RCB A 185,55,50 TELEPHONE CONFERENCE WITH T, YANKEL RE:ARCH
TESTIMONY FILING AND PROPOSED COMMENTS TO IPUC
RE: TESTIMONY, SETTLEMENT STIPULATION AND
INTERVENOR FUNDING
710,1518529 02/24/2006 RCB A 185,111,00 LETTER TO BOARD OF DIRECTORS - REPORT ON ARCH
SETTLEMENT STIPULATION, INTERVENOR FUNDING AND
RELATED ISSUES; TELEPHONE CONFERENCE WITH T,
YANKEL RE: FILING TESTIMONY, PROPOSED
COMMENTS, INTERVENOR FUNDING APPLICATION
710,1518529 02/28/2006 ELO A 175,175,00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:ARCH
SUBMISSION OF TESTIMONY IN SUPPORT OF
STIPULATION; REVIEW YANKEL TESTIMONY AND EMAIL
YANKEL RE: EXHIBIT
710,1518529 03/06/2006 ELO P 175,87,50 GET PRIOR ORDER RE: INTERVENOR FUNDING AND
CONFERENCE WITH RCB RE: SAME
710,1518529 03/09/2006 RCB P 185,277.50 PREPARE APPLICATION FOR INTERVENER FUNDING
710,1518529 03/09/2006 ELO P 175,35,00 CONFERENCE WITH RCB RE: PREPARATION OF
INTERVENOR FUNDING REQUEST
710,1518529 03/10/2006 RCB P 185,277.50 PREPARE PROPOSED APPLICATION FOR INTERVENOR
FUNDING
710,1518529 03/15/2006 RCB P 185,407,00 PREPARE APPLICATION FOR INTERVENTOR FUNDING
WITH ATTACHED EXHIBITS; TELEPHONE CONFERENCE
WITH IIPA OFFICERS RE: SETTLEMENT STIPULATION
INTERVENOR FUNDING REQUEST
710,1518529 03/18/2006 RCB P 185,92,50 RECEIVE AND REVIEW R. LOBB, R. GAIL TESTIMONY IN
SUPPORT OF SETTLEMENT STIPULATION; LETTER TO B,
KLINE PROVIDING EXPLANATION RE: FILING OF
IRRIGATORS TESTIMONY AND RESPONSE TO R. GAIL
TESTIMONY
710,1518529 03/20/2006 RCB P 185,0.40 74,00 TELEPHONE CONFERENCE WITH B. KLINE AND D,
HOWELL RE: T, YANKEL, R, LOBB AND R. GAIL
TESTIMONY AND PROPOSED IIPA COMMENTS IN
SUPPORT OF SETTLEMENT
710,1518529 04/08/2006 RCB P 185,666,00 PREPARE IIPA PETITION FOR INTERVENOR FUNDING
AND SUPPORTING COMMENTS TO PUC RE: SETTLEMENT
STIPULATION, YANKEL TESTIMONY, INTERVENOR
FUNDING
710,1518529 04/11/2006 RCB P 185,166.50 IPUC TECHNICAL HEARING VIA CONFERENCE CALL;
EDITING AND FINALIZING AND FILING IIPA COMMENTS
AND PETITION FOR INTERVENOR FUNDING
Billable 37,6867,
TuesdayO4/11/200611:23amASS
OCJ
OJ)
;:a
......
DescriptionDate
Nov. 16 Read testimony and review exhibits of IPCo witnesses Brilz and Pengilly;
take notes and identify possible issues; review how testimony has
changed from the last case; review cost of service study for impact of
Read testimony and review exhibits of IPCo witnesses Tatum, Baggs and
Gale; take notes and identify possible issues; see how the positions in this
case compared to last case and where issues need to be addressed; review
last order of the Commission.
Review testimony and exhibits; determine what data is needed for further
analysis; review data requests and the responses provided in the last case
develop fIrst set of interrogatories.
Review testimony; continue to develop interrogatories; Q864.
Review PacifiCorp s "Load Growth Report" for incorporation of ideas
into the IPCo case.
Review cost of service study results between this case and last case;
determine how allocators have changed from the last case and how much
influence each allocator has; look for abnormalities.
Review data and develop spreadsheet and graphs regarding the
differences between the equation used for the power cost model in this
case (Exhibit 21) and in the 2003 case.
Review PacifiCorp s "Load Growth Report" and concur with people on
the Utah team regarding same; review implication of "Load Growth
Report" on Irrigator s situation in the Idaho Power situation; review
various proposals to see what may apply in this case where growth is very
Dec RevIew workpapers ofBrilz; review interrogatories as well as the
responses received from last case regarding cost of service issues;
incorporate those interrogatories that are appropriate into this case and
develop new ones interrogatories.
Review workpapers of Brilz; review interrogatories as well as the
responses received from last case regarding cost of service issues;
incorporate those interrogatories that are appropriate into this case and
develop new ones interrogatories.
Date il.Description
Review past PCA cases and data; obtain whatever information is possible
from the Commission website; generally establish trends and changes
regarding the PCA calculations and results; review the amount of
variation and true-up there seems to be from year to year.
Review past PCA cases and data; obtain whatever information is possible
from the Commission web site; generally establish trends and changes
regarding the PCA calculations and results; review the amount of
variation and true-up there seems to be from year to year.
Conversation with Budge regarding direction of case; conversation with
Hessing regarding modeling problems and the intent of PCA mechanisms
workings in order to be fair and yet give the Company incentives to keep
costs low; review Order in the Oregon case regarding IPCo' s PCA and
determine impact of sharing equation; draft outline testimony regarding
general problems with accuracy of the model.
In order to understand direction of Irrigation load now and in the future
review of December 1 , 2005 report entitled "Irrigation Peak Rewards
comparison of program to 2004 Irrigation Peak Clipping Pilot Program;
compare load research data and load profiles from other information that
has been provided in the past to better understand shape of irrigation load;
review irrigation load shape with data previously provided by the
Company regarding cost of purchase power by hour.
Conversation with Budge regarding direction of case; additional review
and begin to develop interrogatories associated with December 1 , 2005
report entitled "Irrigation Peak Rewards ; identify shortfall in data
requested previously regarding irrigation load research and what needs to
be provided; review Order 24806 regarding how the Commission
established the PCA sharing mechanism and determine how effective it is
Review data responses to Industrial Customers rust data requests; review
how marginal costs are developed in this case compared to last; compare
calculations of marginal costs with power supply costs in this case;
calculate how marginal costs are impacted by change in natural gas
prices; talk to Hessing about direction of case; review Company s 2004
Integrated Resource Plan; review Company s 2004 sales forecast by rate
Date
Jan.
Description
Review responses to first data request of the Irrigators and assess
adequacy ofthe same; develop follow-up questions regarding data
response 3 b to the Irrigators 1 st set in order to better understand the data
provided; do a detailed review of response to Interrogatory 4 and calculate
average load factors and total costs in order to compare those that the
Company proposes to remove from the Schedule 24 with the overall
average of those on the Schedule; take the raw data from the AMR project
that was provided in response to interrogatory 5a and try to put it in a
more usable form for comparison with the irrigation load in general and
the load research information the the company collects.
Review data provided in response 5a regarding the AMR data collected
for irrigation customers: change from text format to Access: develop
queries in order to separate out the data regarding when the individual
customers use energy by hour by the month and convert to Excel; develop
separate queries that group data by hour of the month, convert to Excel
and compare/reconcile data with other data from other queries developed
Review the the data supplied and computer models supplied in response
to question #6 of the Irrigator s flfst set of data requests; review in detail
the cost of service computer models that support the three sets of cost of
service results in the Company s case; track the development of allocation
factors back to their source, study impact of changing various allocation
values on cost of service results; develop additional cost of service run
that would include the impact of the unweighted run of the Company as
well as the normalized demand value run of the Company; track changes
though functionalization study; determine how distribution demand
factors impact results of cost of service study.
Review the data supplied and the Computer models and information
supplied in response to question 7 ofthe Irrigator s fist set of data
requests; review input data to Company Exhibits 20 and 21; review input
data to Aurora model supplied in response to request 5 of the First
Production Request of the Industrial Customers of Idaho; review variance
in predicted net power supply expenses that come from the model and the
logarithmic equation that is derived; note variations in years of similar
water; graph results; develop outline for some testimony.
Date
0.0
p.,......
Description
Review data responses supply by the Company associated with questions
13 of the Irrigators' first set of production requests; extract hourly data
for each sampled irrigation customer and develop the format to
summarize data into a form that could be compared the AMR data that
was supplied in response to Irrigation request #5; given the obvious size
differences, develop a method to determine if the AMR data and the load
research data generally tracked each other.
Review data responses supply by the Company associated with questions
14-17 of the Irrigators ' first set of production requests; determine how
hourly data was filed regarding wholesale transactions; group wholesale
sales and purchase data for OS and SF in a manner that broke out how the
price by time of day and by price such that the range of prices and
quantities at each price could be determined.
Review cost of service studies provided by the Company; insert various
values for demand to see why counter intuitive results come about with
respect to the irrigation load and the increase in allocations compared to
the last case; try to determine why the Company s three cost of service
studies have different rates of return for the total company; talked to Brilz
about the same; applied weighting factors based upon growth as opposed
to present usage; ran cost of service study with new values.
Write draft testimony regarding cost of service issues associated with the
inappropriate use of present day billing determinants in order to define
forward-looking" costs on the system; develop graphs of historical data
associated with loads as well as plant-in-service costs.
Develop cost-of-service model runs to compare the Traditional
Normalized, Unweighted studies ofthe Company s with a combination
model to reflect Normalized and Unweighed in the same model run; find
and develop data to reflect the same five years of growth on the system as
the marginal weighting factors are based upon; develop model runs that
reflect the normalization of growth on the system for the next five years.
Draft testimony regarding the company s power supply costs and the PCA
sharing mechanism; develop numbers to support same; draft testimony
regarding the growth that has been taking place on the system and the
difference in growth and the treatment of those costs between rate classes.
Date Descri tion
Draft testimony regarding the growth that has been taking place on the
system and the difference in growth and the treatment of those costs
between rate classes; discussion with Budge regarding draft testimony
concerning power supply costs and the allocation of growth issue that I
Further develop testimony on the PCA and the growth related issues;
develop additional data as well as graphs to make points; work on graphs
to express the difference in billing determinants and costs being allocated;
go over testimony again to insure read-ability and correct mistakes.
Conversation with Budge regarding discovery dispute, prepare for and
attend phone conference with Idaho Power in order to work out discovery
issues related to the Irrigator s 3rd set.
Review the Company s data responses 1 through 7 of Micron s first set of
discovery; review the Company s data responses to Irrigators second set
of discovery; rearrange the Company s load research data to determine if
any of the sample customers were taking interruptible service; review
load research summary reports provided by the Company in discovery.
Review the Company s data responses 8 through 16 of Micron s first set
of discovery; review the Company s data responses to Irrigators second
set of discovery; rearrange the Company s load research data to determine
if any of the sample customers were taking interruptible service.
Review historical data to establish the routine times when the Idaho
Power system peaks during the summer; review sample data from peak
clipping program in order to examine various patterns of usage and
interruptions that occurred during the summer; review Idaho Power
additional responses to Irrigator s third data request.
Feb.Review the data supplied by Idaho Power in response to the Irrigator s 3rd
data set; talk to members of Idaho Power regarding their data responses in
order to develop a better understanding of what was contained in the data.
Manipulate data regarding the load research from the peak clipping
program in order to understand how interruptions are being spread across
days of the week and by size of customer; graph usage data by day
through the summer season for those on the peak clipping program.
Date
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......
Description
Assess how the peak clipping program worked in 2005 verse 2004 which
was the test year and a pilot program for the peak clipping program.
Go over draft testimony with Budge and make notes on areas that need
clarification; develop direction regarding load interruption testimony;
review load research regarding irrigation interruptions.
Attend settlement conference via phone; address revenue requirement
issues and rate spread issues; conversations in between with Budge
regarding progress of settlement conference.
Prepare for and attend settlement conference via phone; discuss various
options with Budge regarding settlement and alternative proposals.
Continue to work on settlement issues and issues important to the
Irrigators; review responses to Staffs 5th set of discovery.
Review latest settlement proposal and determine impact upon Irrigators.
23 Review draft testimony and develop testimony for Stipulation hearing.
Total 207 /"Irs (9) 41'J. S' Ar. =ZS; 61.5"